AIR EMISSIONS PERMITTING

What types of facilities require air permits? 

Due to lowered regulatory thresholds, a wide variety of facilities can now require air emissions permits. These include: 

• Printing operations
• Auto body shops
• Asphalt plants
• Industrial facilities with boilers
• Incinerators
• Landfills
• Industrial facilities with air pollution control equipment
• Certain types of construction projects
• Facilities with diesel engines and/or emergency generators
• Construction Processing Equipment used at multiple sites

Any time a new facility is to be built, or if additional equipment is to be placed at this service, it should be determined whether or not an air emissions permit is needed. A number of years ago, permitting thresholds were high, but, currently, due to incursions of National Ambient Air Quality Standards, in many localities, some types of facilities emitting as few as several pounds per day of particulates (dust) or volatile organics, require air emissions permits. If permit applications are not filed in a timely manner, construction can be stopped and fines can be levied. 

How complicated are air permit applications? 

The complexity of air permit applications depends directly on the type of air emissions source being permitted. Some types of permit applications are relatively simple, for example, those for small paint booths, or, those for low horsepower diesel generator engines. Other permit applications can be more complicated, particularly for new facilities with multiple sources, or for existing facilities undergoing major changes in equipment, or equipment replacements. Regulations which need to be complied with are both on the federal and state level, and need to take into account one or more of the following programs: 

• Pennsylvania Air Regulations
• EPA Air Regulations
• Prevention of Significant Deterioration Program
• New Source Performance Standards, BAT and/or SOTA requirements
• Title V Permit Requirements
• Requirements for Emissions Offsets, when in a National Ambient Air Quality Standard non-attainment area, for certain emissions parameters.

How long does it take for permit applications to be processed and approved? 

In addition to taking a matter of weeks or months to prepare most air permit applications, regulatory agency processing and approval times are variable, depending principally on the number of programs and/or regulations under which the permit will need to be issued, and depending on whether the facility is or is not a major source, and the complexity of an industrial plant and/or a number of sources or permit modifications involved. 

Another factor is whether or not the emissions contain Hazardous Air Pollutants (HAPs).  These are certain pollutants which are specially regulated. Where HAPs are present, maximum achievable Control Technology may be required. Generally, it takes 90 to 120 days for processing and approval of the most straightforward permit applications. Where there are complex air sources, or where there may be public involvement, permitting can take from six months to a year. Air permit applications should be prepared well in advance of any specific needs to install new equipment, or upgrade existing equipment. 

RT Experience 

RT’s Staff has experience in a wide variety of air permitting situations, from small sources with particulate filters, to larger sources, involving Title V permits, and even including those requiring Prevention of Significant Deterioration permit approvals. Facilities at which our staff has experience include sludge incineration, asphalt plant emissions permitting, food production, dyeing products manufacturing, remediation systems air emissions, paint booth and air emissions and large scale mobile equipment painting/manufacturing. 

Please call Gary Brown at (800) 725-0593 for more information or questions regarding Indoor Air Quality, or use the Request for Services form to obtain a proposal within 24 Hours.